1.

General information

This document ("Privacy Policy") describes how Challengermode AB, a Swedish limited liability company with company registration no. 556989-7498 having its registered address at Malmskillnadsgatan 36, 111 57 Stockholm, Sweden ("Challengermode", "we", "us", or "our"), can collect, use, and process Your personal data. Challengermode is data controller regarding the processing of Your personal data as described in this Privacy Policy.

This Privacy Policy applies when You use the Platform. Please notice that upon using the Platform, You may be directed to websites or services provided by third parties where Your personal data is processed by such third parties and governed by their respective privacy policies.

All definitions in this Privacy Policy shall be interpreted in accordance with applicable data protection laws which refer to the General Data Protection Regulation (Regulation no. 2016/679) and the Directive on Privacy and Electronic Communications (Directive 2002/58/EC), as well as the national implementations and related national legislation. Definitions specified in the Terms of Use shall also apply to this Privacy Policy.

2.

What Personal Data does Challengermode process?

Challengermode process Your personal data for different purposes. Hereunder follows a table describing what personal data we process, our purpose for the processing of Your personal data and our legal basis for the processing Your personal data.

Purpose for processing

Personal data about you

Challengermode's lawful basis for processing

To administrate Your User Account

  • E-mail address
  • Password
  • Profile picture
  • Username
  • First and last name
  • Address
  • Telephone number
  • Payment information
  • Birthdate; and
  • Country

The processing is necessary for us to comply with our contractual obligations towards You, such as creating and managing Your User Account and allowing You to participate in competitions.

To offer You to participate in competitions and activities relevant to Your location and age

  • Country
  • Birthdate
  • Address; and
  • IP address

It is our legitimate interest to process Your personal data for being able to give You the best user experience. It is necessary for us to gather Your personal data to be able to present relevant activities to You.

For verifying your in-game identity and verifying match results in competitions, as well as to gather match and game statistics

  • Game account (for example Steam account or Riot Games account)

The processing is necessary for us to comply with our contractual obligation towards You.

To verify your identity and prevent fraud

  • E-mail address
  • Phone number
  • IP-address
  • Username
  • First and last name
  • Country

It is our legitimate interest to process Your personal data for being able to prevent fraudulent behavior and comply with laws and regulations.

For managing support questions and complaints

  • E-mail address
  • First and last name; and/or
  • Username

It is our legitimate interest to process Your personal data for being able to help You with support questions. It is necessary for us to gather Your personal data to be able to assist You with Your questions.

If Your question is regarding a complaint, we will process it on the lawful basis of fulfilling our contractual obligation.

In order to send you direct marketing material about our new features and games

  • E-mail address
  • First and last name; and/or
  • Username
  • Gameplay data and statistics

It is our legitimate interest to process Your personal data for the purpose of sending You direct marketing material. You have an absolute right to object to the processing of Your personal data for direct marketing.

In order to send you important messages about your account and updates to our terms and policies

  • E-mail address
  • First and last name; and/or
  • Username

The processing is necessary for us to comply with our contractual obligation towards You.

In order to handle Your request to opt-out from our advertisements

  • E-mail address
  • First and last name; and/or
  • Username

It is our legitimate interest to process Your personal data to handle Your request to opt-out from our advertisements.

Promoting Your victories and market our Platform

  • Username
  • Gameplay data and statistics
  • Tournament records; and
  • Any other information with regard to Your gaming activity

It is our legitimate interest to process Your personal data to enable us to highlight participants on the Platform and to market our Platform.

Showing and recommending relevant content, competitions, and information on the Platform.

  • Technical information, such as Your IP-address, browser information, preferred language, as well as the OS You use.
  • Competitions and activities that you have participated in or organized.

It is our legitimate interest to process Your personal data for the purpose of recommending relevant competitions and platform content to you.

We collect Your personal data directly from You, for example when You register a User Account. We also collect Your personal data from third parties, for example if you choose to register Your User Account by using Your Facebook account or connect a game account.

We are not able to provide the Platform to You without processing Your personal data as described above.

3.

Disclosure and transfer of personal data

Your personal data may be disclosed to Organizers, sponsors or partners when You participate in activities or competitions hosted by them.

We may also disclose Your personal data to service providers that we use to provide the Platform. The service providers consist of the following categories: (i) payment solutions, such as PayPal and (ii) IT services providers.

Challengermode will not intentionally disclose or share any personal data about You to third parties without Your consent, except where Challengermode, in good faith, believes such disclosure is necessary to comply with applicable law or contractual provisions in our Terms of Use.

Challengermode always tries to process Your personal data within the EU/EEA. However, in some situations, as described in the table below, Your personal data may be transferred to and processed in a country outside the EU/EEA. We are therefore applying appropriate safeguards for the transfers to these recipients through one of the following measures:

  • The country of destination is on the European Commission's list of countries with an adequate level of protection; or
  • By implementing the relevant module (as applicable) of the European Commission's standard contractual clauses.

When transferring personal data based on the European Commission's standard contractual clauses, we will assess the level of protection provided by the third country and take additional technical or organizational measures to ensure a sufficient level of protection for the transferred personal data if necessary.

Recipient

Location

Transfer Mechanism

Microsoft

EU, USA

Standard Contractual Clauses

Google

EU, USA

Standard Contractual Clauses

Twilio (Sendgrid)

USA

Standard Contractual Clauses

Copper

USA

Standard Contractual Clauses

DocuSign

USA

Standard Contractual Clauses

Checkout.com

EU, USA

Does not transfer data outside of the EEA as a processor

Tipalti

USA, EU, UK

Standard Contractual Clauses

Meta (Facebook)

EU, USA

Standard Contractual Clauses

Slack

EU, USA

Standard Contractual Clauses

If you wish to access or obtain a copy of the standard contractual clauses or receive other information about the safeguards or the transfers, you can contact us using the contact details set forth below.

Challengermode reserves the right to collect and disclose general demographic and other market information that do not personally identify You, to any person, without Your additional consent.

4.

Cookies

A "cookie" is a small text file sent from Challengermode's server to Your browser. The cookie cannot identify You personally and can only recognize the browser that is installed on Your computer which is used to access the Platform. Different cookies are sent to different computers if You access the Platform from different computers. Cookies are required for the Platform to function correctly and safely, for example when You login to Your User Account. Cookies are also used to measure the data traffic to the Platform and for statistical reasons.

There are two types of cookies: one type is called "session cookies", and the other is called "permanent cookies". The Platform uses both session cookies and permanent cookies.

A session cookie is sent between Your computer and Challengermode's server in order for the Platform to work properly during Your visit. A session cookie disappears when the browser is closed and is thus not stored on the computer.

A permanent cookie is stored in Your computer and allows the Platform to recognize Your computer's IP address and web browser the next time You login.

You can opt-out from our use of cookies on Your computer by editing a setting in Your browser. Such settings may imply that certain functions on the Platform will not function properly or be available.

5.

Storing of Personal Data

Your personal data will be stored as long as You have an active User Account. Eleven months after Your last login You will receive a reminder on Your inactivity. Upon further inactivity, Your User Account will be blocked. Two years after Your last login, Your User Account will be deleted due to inactivity unless the data is required for a specific reason or Challengermode has agreed with You to store the personal data for a specified period. Challengermode reserves the right to delete personal data earlier if Challengermode deems it appropriate.

6.

Your rights

Below are the rights that You have under applicable data protection law. If You wish to send a request regarding any of Your rights, please contact us via the e-mail address under section 10.

In order to meet Your request, the request needs to be as specific as possible. Please use indicators such as: the type of data, the type of document, the involved function/business department and/or the involved contact persons etc. Your request cannot be processed if the request is not specific or clear.

Right to Access - You have the right to request access and further information concerning the processing of Your personal data. You have a right to obtain a copy of the personal data that we process relating to You free of charge once (1) every calendar year. For any additional copies requested by You, we may charge a reasonable fee based on administrative costs.

Right to Rectification - If the personal data Challengermode holds about You is inaccurate or not complete, You have the right to ask us to rectify or complete it. If that personal data has been passed to a third party with Your consent or for legal reasons, we will also ask them to rectify or complete Your personal data.

Right to Erasure or Restriction - You have the right to erase or restrict the processing of Your personal data.

Right to Object - You have the right to object to Challengermode's processing of Your personal data based on our legitimate interests.

Right to Withdrawal - If You have given us Your consent to process Your personal data but change Your mind, You have the right to withdraw Your consent at any time, and Challengermode must thenthan discontinue the processing of Your personal data based on Your consent. The withdrawal of Your consent does not affect the lawfulness of the processing based on the consent before its withdrawal.

Data Portability - If the processing is based on the legal grounds consent or fulfilment of contract, You have the right to data portability. Data portability means that You can receive the personal data that You have provided to us, in a structured, commonly used and machine-readable format, and have the right to transfer such personal data to a thirdto third party.

7.

Children

The Platform is not directed to persons under the age of thirteen (13). If you are a parent or guardian of a person under the age of 13 and you become aware of that the child has provided personal data to us without your consent, please contact us via the e-mail address under section 10.

8.

Complaint

If You have any complaints regarding our processing of Your personal data, You may file a complaint to the Swedish Data Protection Authority (Sw. Integritetsskyddsmyndigheten) if You feel that Challengermode has not adequately responded to Your request.

9.

Notice of changes to the Privacy Policy

This Privacy Policy may occasionally be updated, therefore, You shall read this Privacy Policy periodically. Any amendments to this Privacy Policy will be published on the Platform and, where appropriate, notified to You in writing. Significant changes to this Privacy Policy will always be sent to You via e-mail.

10.

Contact us

If You have any questions regarding this Privacy Policy or wish to exercise any of Your rights, You can contact us on the below phone number and address:

Phone: +46(0)8 - 121 595 40

Address: Challengermode AB Malmskillnadsgatan 36, 111 57 Stockholm, Sweden